Part II: Tools for an effective follow-up and implementation and recommendations’.244 In addition it also suggests that NPMs should ‘establish a strategy for making its mandate and work known to the general public and should establish a simply [sic] and accessible procedure through which the general public might provide it with relevant information.’245 With respect to any publicity that a report and its finding generate, the NPMs consulted in this Project use publicity in two ways: on the one hand to generate more awareness and support for the work of the NPM, its findings and recommendations, and on the other to put pressure on the authorities and promote the implementation of specific recommendations. The extent to which there is publicity, however, will depend on the extent to which the recommendations are detailed in the various reports. œœ Publication and dissemination of annual reports According to article 23 OPCAT NPMs are obliged to publish their annual reports and all NPMs consulted as part of this Study, with the exception of Malta do so. Moreover, some NPMs hold press conferences to present their annual report (e.g. in Austria, Bulgaria, Croatia, France) and in this framework give interviews to newspapers, TV and radio stations. Most NPMs also present annual and thematic reports in the Parliament (see Part II, Chapter 2.1). œœ Publication and dissemination of visit reports While the OPCAT is silent in respect of the publication of NPM´s visit reports, the great majority of NPMs also publish and disseminate visit reports (e.g. Cyprus, Estonia, France, Germany, Lithuania, Luxembourg, Netherlands, Poland, Slovenia, Sweden and UK) while others publish a list of their recommendations (e.g. Bulgaria, Croatia and Spain). There are some NPMs that also publish summaries of their visiting reports in English, e.g. Estonia or Slovenia. The German NPM did not publish its visiting reports at the outset, but changed its approach in order to make them accessible to other institutions, as well as CSOs. It also aimed to increase the transparency of its work and to make it more interesting for the media. The consulted NPMs publishing their reports consider this as an important element to generate publicity for the NPM. Moreover, the APT emphasises that it promotes transparency and accountability.246 The published reports are considered to provide a ‘reference point’,247 which helps the Government to understand the methodology and standards that the NPM applies, and contributes to the mutual strengthening of standards for detention conditions. The publication of the visit reports can be a useful and easy way to disseminate information on any measures taken to comply with recommendations in previous reports. For example in the UK, the HMIP publishes its visits reports to prisons and these include a section on information on progress on recommendations since the last report. At the same time, as noted above, there may be instances where more impact may be achieved by keeping a visit report confidential at first in order to build constructive dialogue with the relevant authorities. Therefore, NPMs considered it important that they should be free to make strategic decisions on the publication of their reports. In addition, NPMs need to adopt a ‘do no harm’ approach, and take measures to prevent reprisals or threats. Most NPMs publish their visit reports without specifically approaching journalists and wait for the media to respond. Others, such as the HMIP in the UK generally share the embargoed visit reports with the local press a day before their publication, with a press briefing sometimes following. HMIP also responds to interview requests by the press. Most NPMs do not release their reports immediately after a visit but only after the internal procedures are concluded and the responsible authorities have had the opportunity to comment. This process can take up to several months and some NPMs at the Vienna workshop noted that the delay in publication can lead to a decrease of interest by the media. Ibid para 33. Ibid. 246 See also APT and IIHR, Implementation Manual (2010) 244. 247 APT and OSCE Office for Democratic Institutions and Human Rights (ODIHR), Monitoring places of detention: a practical guide for NGOs (2002) 69. 244 245 - 82 -